Top Story:
The Supervision Peer Review Working Groups: An Interview with Grace Dailey and Darrin Benhart

04/04/2014

By Joe Adamoli
Public Affairs Operations

Comptroller Curry asked Grace Dailey, Large Bank EIC, and Darrin Benhart, Deputy Comptroller for Credit and Market Risk, to lead two working groups to assess the recommendations in the Supervision Peer Review Report and to develop proposals based on the recommendations. Dailey led the Process Improvement Working Group and Benhart led the Policy Enhancement Working Group. SuperVisions sat down with the team leaders to get their thoughts on the working groups and their efforts to assess the supervisory processes and supervisory policy recommendations.

S/V: Both working groups were a diverse, cross-section of of OCC staff, including NTEU members. Why was this important?

Dailey: The different perspectives were critical to addressing the recommendations. Each person brought something unique to the group. It was important to have representatives from each of the CBS [Committee on Bank Supervision] units, as several of the recommendations touch all examiners. Knowledge of how LBS [Large Bank Supervision] is currently structured and what changes may be feasible was key to several of the recommendations. Awareness of the Midsize structure and processes was beneficial to help us think through our structure and process recommendations. Familiarity with the various strategic initiatives that are currently in progress and overlap with some of the report’s recommendations was also very helpful. A number of the recommendations in the [Supervision Peer Review] report implicate HR matters, so HR input was very valuable. Having NTEU representatives involved in the discussions early on—through pre-decisional involvement—should aid the labor management aspects of potential implementation.

Benhart: I echo Grace’s comments about the value of a diverse team. My team was made up of people from CNBE [Chief National Bank Examiner], LBS, Legal, Economics, and MCBS [Midsize and Community Bank Supervision]. The diversity and experience of my team really helped us develop ideas and proposals. We were still sometimes challenged, even with the diversity of the team, to identify all the existing initiatives that touched on the items in the report.

S/V: What process or strategy did your group follow when discussing the report recommendations in order to build consensus and develop options?

Benhart: My team worked in a collaborative manner and I was happy about that. We grouped the recommendations into three themes. Then we investigated things internally—reaching out to folks within the OCC who we thought might have something to contribute. We reached out to the peer review team members for clarification on a few items, and conducted a great deal of research. We also formed mini teams that developed some solutions that the entire team then challenged to reach consensus on proposals.

Dailey: We followed a similar process where we mainly brainstormed as a group and collectively discussed the pros and cons of the various proposed actions and options. We also conducted significant fact gathering.

S/V: How did you go about facilitating the working group meetings?

Dailey: We treated the process much like an examination. I assigned a lead and small team to each of the recommendations. During our in-person meetings, we brainstormed ideas, vetted proposals and options, discussed progress, next steps, etc. In between meetings, the leads and teams would meet in person or by phone and research various aspects of their assigned recommendation and draft written proposals. Written products with proposed actions and options were shared with the team as they were developed.

Benhart: My group followed a similar process. At the end of the day, most of us are examiners or have supported our examination process for a long time so we brought that experience to this effort. The challenge for me was to make sure the team came back to the task at hand. Like all teams, we got into other detailed conversations so I was the person saying, “Let’s not forget that we need to bring this ship into the dock.”

S/V: Was there anything about the meetings that surprised you or was otherwise noteworthy?

Benhart: My group was really surprised at the number of existing initiatives and projects that already address all or some aspect of the peer report recommendations. Much of our work focused on the need to ensure collaboration and in many cases consolidation of the work that was under way. We identified some opportunities where there was overlap and where consolidation would be logical. I want to express my appreciation to my team members for the time they spent on this effort and to the other OCC employees who took the time to collaborate with my team.

Dailey: We were surprised to see that the data showed that a lot of activity occurs around rotations of positions/assignment, albeit informally. It highlighted that perceptions—including some of our own—are at times based on a couple of examples or anecdotes, rather than actual information.

S/V: One report recommendation calls for relocating some resident staff in banks to common OCC premises. Grace, how would you describe your team’s discussion on this particular topic and the development of options for consideration?

Dailey: We focused on our objectives and developed options based on those. As some of the other recommendations came together, it became more clear to us that several of the proposed actions worked together. We also spent more time discussing the pros and cons of the options, as the ultimate direction, which has not yet been determined of course, may depend on the relative weight given to the various pros and cons.

S/V: Employees will be able to provide feedback on your groups’ proposals from April 7 through April 18. How should employees view this opportunity?

Dailey: It seems somewhat similar to a notice of proposed rulemaking process. I hope employees take advantage of providing constructive responses that could help shape the final proposals. The working group will review and consider the comments before submission to the executive sponsors. It will be helpful to see if there are consistent themes in the comments or if a new suggestion, or a twist on one of the group proposals, is determined to be a better path to meet the objectives.

Benhart: We want employees to take advantage of this opportunity. Many of my team’s recommendations deal with how we implement and communicate priorities, how we make decisions, as well as how we look at risk horizontally across the agency and take action from a supervision standpoint. Those were the three basic themes that we broke out. Some may view those as more Headquarters centric, but they do have clear implications for the field. If employees have a better way to build this mousetrap, we want to hear from them.